Introduction
This modern slavery and human trafficking statement ("statement") is made pursuant to section 54 of the Modern Slavery Act 2015. It applies to Gallagher Bassett International Ltd and each of the companies listed in Appendix 1 (referred to as the "Companies", "our", "we" or "us").
This statement is in respect of the financial year ending 31 December 2024 and outlines the steps that we have taken and continue to take to ensure that modern slavery and human trafficking are not taking place within any part of our business or in any of our supply chains.
Our ethics
We are committed to implementing effective systems and controls to ensure neither slavery nor human trafficking occur within any part of our business or in any of our supply chains. Our ongoing commitment to ethics has been integral to the ultimate parent company of the Companies, Arthur J. Gallagher & Co, since it was established in 1927.
Our leadership sets the tone for our distinct culture and senior level accountability ensures commitment to do what is right for our customers and the communities that we operate in.
Group structure
Arthur J. Gallagher & Co, its subsidiaries and affiliates, including the Companies (together the "Group") employs approximately 56,000 employees worldwide, with around 7000 employees based in the United Kingdom.
Our business
The services we offer encompass claims and risk management solutions, legal services, loss adjusting and consultancy solutions. These services help people and businesses prevent, manage and overcome the impact of risk.
Our supply chain
The Companies seek to promote best practices, and formal policies are in place that establish a governance and control framework for suppliers.
This includes sourcing and evaluation processes for supplier selection, the agreement of transparent and regulatory compliant contractual terms, and continuous engagement.
Suppliers used by the Companies include maintenance and support of our offices, including cleaning and technical support services for office infrastructure and IT, and for outsourcing certain functions ordinarily performed by the Companies.
The Companies utilise certain offshore business process outsourcing services in India. A key factor is that the service providers in India are part of the Group, rather than third-party business process outsourcers, and all of their staff are Group employees. They perform various functions that are essential to the delivery of services to our clients. They remain committed to our approach to the management of modern slavery and human trafficking risk, and the integration of our policies and training is ongoing. This includes addressing employee well-being, risk management and establishing a process for reporting risk events.
Due diligence process
Certain suppliers are required to complete a Request for Information ("RFI"), as part of the selection and on-boarding process, to assess their ability to comply with a range of requirements including legal, regulatory and financial. This includes compliance with modern slavery and human trafficking reporting requirements.
As determined by spend and risk, our critical service suppliers to the Companies will be required to provide comprehensive information and disclosures through our Environmental, Social and Governance ("ESG") Supplier Attestation Questionnaire. This includes modern slavery, human trafficking and labour standards, and we expect it will aid us in continuously improving our approach to supply chain management and the prevention of modern slavery and human trafficking.
Our policies and governance
The Companies are committed to upholding the highest standards of moral, professional, and ethical behaviour. We prioritise acting with integrity and transparency in all our business relationships. We therefore expect our supplier network and those involved in procurement for the Companies to comply with the Gallagher Global Standards of Business. These standards can be accessed by visiting: https://www.ajg.com/about-us/global-standards/.
The 'Gallagher Way' serves as a statement of shared values within Gallagher and forms the foundation that underpins the Group culture. In addition, there is a suite of core policies in place which reinforces our commitment to upholding the highest professional standards and ethics, both within the workplace and in our business dealings with others.
The Companies have various policies and processes aimed at minimising the risk of modern slavery and human trafficking. These measures also encourage the reporting of any concerns related to these issues. Some of these policies and processes include:
- A Modern Slavery Policy, which outlines the expected behaviours for all employees and provides guidance on the reporting procedure and obligations.
- Supplier Code of Conduct, which outlines our expectations for suppliers in terms of ethical conduct, human rights, labour practices, and environmental stewardship. By adhering to these principles, we aim to foster a responsible and sustainable supply chain.
- A Whistleblowing Policy, that ensures all employees are aware of how to raise concerns about the treatment of colleagues or any practices within our business or supply chain, without fear of reprisal. There have been no reported incidents related to suspected modern slavery or human trafficking activity.
- Recruitment processes that, amongst other things, mitigate against the use of external agencies that do not adequately safeguard individuals offered for roles and include robust Right to Work checks.
- Where relevant, we aim to incorporate a requirement for compliance with modern slavery legislation into our standard terms and conditions and contractual arrangements.
Training
New employees undergo training as part of their induction programme and existing employees undergo annual training, which includes information on who they should contact if they have any concerns about modern slavery or human trafficking. Employees are also encouraged to report any concerns or suspicions regarding the presence of modern slavery or human trafficking within the supply chain.
Modern slavery is also included within the Group's global "Leading with Integrity" training module, which is assigned to all new and existing employees on an annual basis.
By implementing this training, we actively encourage our employees to contribute to the eradication of modern slavery and to establish a safer and more ethical working environment for everyone involved.
Looking ahead, continuous improvement and ambition
To improve the oversight of our modern slavery risk, our UK & EMEA ESG Committee is leading on shaping how we assess and report on the risk of modern slavery.
We embrace a culture of continuous improvement, striving to incorporate best practices in all aspects of our operations. By doing so, we aim to and continue to take steps to ensure that modern slavery and human trafficking are not taking place within any part of our business or in any of our supply chains, including the following:
- Perform gap analysis, consultancy and training when required.
- Continue to deploy tailored modern slavery training to key employees in order to raise awareness of modern slavery and human trafficking, identify specific risks, and promote effective reporting of any concerns related to modern slavery or human trafficking.
- Continue to roll-out best practice to support consistency across the Companies.
- Continue to be vigilant in monitoring and reporting any suspected instances of modern slavery and human trafficking and encourage employees to report through the appropriate channels.
- Continue our ongoing work with UK critical service suppliers, including addressing any improvement actions that arise from the ESG Supplier Attestation Questionnaires.
- Reviewing and updating our ESG Supplier Attestation Questionnaire to reflect evolving requirements and standards.
- Review our Supplier Code of Conduct to outline our expectations for suppliers, with the aim of fostering a responsible and sustainable supply chain.
- Continue to work alongside our partnerships and to collaborate with industry.
- Undertaking modern slavery due diligence checks where we explore intra-group services from high-risk overseas territories.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Gallagher Bassett International Limited on 26 June 2025.
Appendix 1
- Camco One Ltd
- Claims Settlements Agencies Ltd
- Countrywide Accident Assistance Limited
- Gallagher Bassett Insurance Services Limited
- HMG-PCMS Ltd
- Strata Solicitors Ltd
